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. … Hélie Holdco served only to participate in the transaction for the benefit of Mr. ...

Similarly, respecting the divestiture-related fees of Lazard Frères incurred up to board approval of a butterfly spin-off, these related to advice and approaches to potential third-party purchasers of the shares through which the laminated products business was held as well as to the ultimate sale (on a rollover basis) of the shares of that laminated products company to Novelis in consideration for the acquisition of (subsequently redeemed) preferred shares of Novelis, and the calculation of the Lazard Frères success fee did not represent a percentage of the value of those shares – so that those fees also were deductible under s. 20(1)(bb) as well as under s. 9. ...

. … I am inclined to favour a narrow construction of double taxation such that it arises where the same amount is taxed in the hands of the same person. ...

. … [T]he leasehold interest that FSL obtained from ADL at a nominal rent under the New Ground Lease was a capital asset [having cited T Eaton, 99 DTC 5178, para. 36] and therefore that the payment made by FSL by offset on behalf of ADL was on capital account. ...

Since the payment of the sums … to the City of Chandler had the effect of freeing the appellant of its obligation to negotiate in good faith to create a limited partnership, the consideration received by the appellant in exchange for such payment was the amount by which that obligation was extinguished. ...

Section 97 uses the phrase “immediately after... the partnership... acquired the property” in subsection 97(1) …. ...

The MGICs were also the sole members of a non-share corporation (“Groupe Promutuel,” or the “Federation”) which did not have any capital participation in ProRé, and whose affairs were administered by a board of directors consisting of 10 individuals – seven directors and three managing directors of different MGICs. ...

Before granting the amendments, D’Auray J indicated that Rule 132 applied only to “formal admissions” such as in pleadings Andersen Consulting ([1998] 1 FC 605 (FCA)) had established “that an application for leave to withdraw admissions did not require a separate form” (para. 75), so that the requested amendment to the Reply could constitute application to withdraw an admission In Burlington’s examination for discovery of the Crown’s nominee in 2014, “[n]umerous times the respondent’s counsel stated that it was the respondent’s position that no amounts were payable as guarantee fees” (para. 77) Although in an Amended Reply, the Crown had admitted that guarantee fees had been paid in the amounts stated in the Notice of Appeal, “the respondent did not make a clear and deliberate concession that the amounts paid to BRI were guarantees fees” (para. 80) in light of the point immediately above and denials made by the Crown elsewhere in the Reply Even if there had been such an admission, D’Auray J “would still have permitted the withdrawal of the admission since … there is a triable issue which ought to be tried in the interests of justice” (para. 82) “In addition, the purported withdrawal does not amount to an injustice to Burlington since it has been aware of the respondent’s position at least since its discovery of the respondent’s nominee in 2014.” ...

Had it been received, “the payment of the 833,333 LEO shares would have been a payment to Lockwood for services rendered [and] hence … business income” (para. 64). ...

That being the case, the alternative transactions involving the sale of 3295940 shares cannot be submitted for comparison …. ...